## For EPA Use Only ID # ______________ SECTOR _________________________

Under the Clean Air Act and the international treaty to protect the ozone layer (the Montreal Protocol on Substances that Deplete the Ozone Layer), the production and import of methyl bromide was phased out in the United States on January 1, 2005. This application seeks information to support a U.S. request to produce and import methyl bromide for certain critical uses and circumstances beyond this 2005 phaseout date. The information in this application will be used to review whether your use of methyl bromide is "critical" because no technically and economically feasible alternatives are available. In order to estimate the loss as a result of not having methyl bromide available, EPA needs to compare data (yields, crops/crop groupings, prices, revenues and costs) for your use of methyl bromide with uses of alternative pest control regimens.

EPA Form # 4900-136 Pre Plant 

### Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Public reporting burden for this collection of information is estimated to average 38 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many individual users of methyl bromide. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current OMB control number. 

## The information contained in this application is critical to process and assess the need for methyl bromide. Filling out this application in its entirety will bolster the U.S. government's ability to strengthen the nomination package for the international review boards. OMB Control # 2060-0482, Expires 6/30/2015



## WHY IS THIS **INFORMA**

**TION NEEDED?**  

# 2013 A **pplication for Critical Use Exemption of Methy l Bromide**  **for Pre Plant Use in the United States in 2016 and 2015**

**Click on the Instructions tab located at the bottom of the screen for additional information.**



# UNITED STA

**TES ENVIRONMENTA L PROTECTION A** **GENCY WA** **SHINGTON, D.C. 20460 WHO** 

**AP PLIES?** 

**WHA T**  **INFORMA**

**TION IS REQUIRED?**  **HOW DO I A**  **PPLY?**

**WHEN IS THE INFORMA** 

**TION NEEDED?** 

**Mailing A ddress for applications being submitted**  **by mail**  **directly**

**to the EPA :**  **Ad dress for applications being sent by**  **courier or**  **non U.S. Postal overnight express**  **delivery to the EPA**  **:** US Environmental Protection Agency US Environmental Protection Agency Methyl Bromide Critical Use Exemption Methyl Bromide Critical Use Exemption Office of Air and Radiation Office of Air and Radiation Stratospheric Protection Division (6205 J) Stratospheric Protection Division 1200 Pennsylvania Ave, NW 1310 L Street, NW , Suite 1047E Wa shington, DC 20460 Wa shington, DC 20005



# INSTRUCTIONS The information provided by you in this application will be used to evaluate the requested methy l bromide use. The U.S. and other countries that are parties to the Montreal Protocol On Substances That Deplete The Ozone Lay er decided that: "a use of methy l bromide should qualify as "critical" only if the nominating Party

determines that: (i) The specific use is critical because the lack of availability of methy l bromide for that use would result in a significant market disruption; and (ii) There are no technically and economically

feasible alternatives available to the user that are acceptable from the standpoint of environment and health and are suitable to the crops and circumstances of the nomination ..."

EPA Form # 4900-136 Pre Plant **HOW CA N I**  **RECEIVE AD**  **DITIONA L**  **INFORMA**

**TION?** Critical use exemptions are valid for only one y ear and do not renew automatically . Users desiring to obtain an exemption for 2016 must apply

to EPA. Because of the latest changes in registrations, costs, and economic aspects for producing critical use crops and commodities, all applicants will be required to fill out the application form completely . If these W orksheets are not submitted, EPA will not include the application in the U.S. nomination submitted for international consideration.

**When submitting an application electronically , y** **ou should also sign Worksheet 1 and email or fax it to: 202-343-2338**  If you anticipate that you will need methyl bromide in 2016 because you believe there are no technically and economically feasible alternatives, then y ou should apply for the critical use exemption. This application may be submitted either by a consortium representing multiple users or by individual users. W e encourage users with similar circumstances of use to submit a single application (for example, any number of pre plant users with similar soil, pest, and climactic conditions can submit a single application.) If a consortium is apply ing for multiple methy l bromide users, the economic data should be for a representative or ty pical user within the consortium unless otherwise noted. If economic or technical factors (such as size of the farm) affecting the ability of this "representative user" to use alternatives are significantly different than other users in the consortium, more than one application should be submitted to reflect these differences. Please contact your local, state, regional or national commodity association and/or state representative agency to find out if they plan on submitting an application on behalf of y our commodity group.

**IS MY INFORMA** 

**TION CONFIDENTIA**  **L?**

If you have general questions about this application call the Stratospheric Ozone Hotline at:

1-800-296-1996 More information is also at http://www.epa.gov/ozone/mbr **WHERE DO I SUBMIT THE**  **AP PLICA** 

**TION?** Yo u may

either complete an electronic (Microsoft W ord or Excel) or a printed version of the application. Please fill out each section in the application as completely as possible. If you are completing the printed version and need extra space y ou may attach additional sheets as needed.

Information covered by a claim of confidentiality will be disclosed by

EPA only

to the extent, and by means of the procedures set forth under 40 CFR Part 2 Subpart B; 41 FR 36902, 43 FR 400000. 50 FR 51661. If no claim of confidentiality accompanies the information when it is received by EPA, it may be made available to the public by EPA without further notice to the applicant.

**Electronic A**

**ddress for applications: arling.jeremy @epa.gov**  Applicants submitting their application via e-mail assume responsibility for the confidentiality

of the electronic message transmission. This application must be postmarked to the EPA address below no later than **Au gust 29** 

. OMB Control # 2060-0482, Expires 6/30/2015

The applicant may

assert a business confidentiality claim covering part or all of the information in the application by placing on (or attaching to) the information, at the time it is submitted to EPA, a cover sheet, stamped or ty ped legend, or other suitable form of notice employ ing language such as trade secret, proprietary , or company confidential. Allegedly

confidential portions of otherwise non-confidential documents should be clearly identified by

the applicant, and may be submitted separately

to facilitate identification and handling by EPA. If the applicant desires confidential treatment only until a certain date or until the occurrence of a certain event, the notice should so state.**SECTIONS OF**

**WORKBOOK**
**Worksheet 1.** Contact and Methyl Bromide Request Information

**Worksheet 2-D(1&2).** Methyl Bromide - Baseline - Operating Costs for 2012 (Annual or Perennial)

**Worksheet 6.** Application Summary **Definitions Climate Zone Map**  **Worksheet 2.** Methyl Bromide

**2.** A tab with the name “Sheet 1” will appear at the bottom of the worksheet and will be highlighted in white. Take the cursor and double click the “new tab” **3.** By double clicking in the tab y ou can now rename the worksheet to the appropriate number letter designation (e.g., 3-A(1), 3-A(1)(a), etc.) **4.** To move a newly

inserted worksheet, simply drag the worksheet with your mouse to the desired location. **5.** Once you add a new worksheet, Excel will automatically name each subsequently added worksheet as Sheet 2, Sheet 3, etc... Follow the instructions above to rename the new blank worksheets as appropriate. **Inserting a blank worksheet: 1.**  To add additional blank worksheets in the Excel file, go to the menu line at the top of the worksheet and select “Insert” then “worksheet” **Worksheet 3.** Alternatives **Worksheet 2-A .**  Methyl Bromide - Pest and Crop Information

**EXCEL USER TIPS**  **Worksheet 2-B.** Methyl Bromide - Historical Use for 2008 - 2012 

# INSTRUCTIONS **Each w orksheet number corresponds to the tab number in the electronic version of the application.**  **Instructions specific to each w orksheet are provided at the top of each sheet. A**  **header row is included on**  **each w orksheet to include an application ID number that EPA**  **w ill assign.** 

**Worksheet 2-C.** Methyl Bromide - Crop/Crop Grouping Yield & Gross Revenue for 2008 - 2012

**Worksheet 4.** Emission Control **Worksheet 3-A .**  Alternatives - Technical Feasibility of Alternatives to Methyl Bromide

**5.** Again, select the top left corner of the worksheet (left of column A and above row 1) to select the entire worksheet. **6.** Go to the menu line at the top of the worksheet and select “Edit” then “Paste” **Worksheet 3-B(1&2).** Alternatives - Changes in Operating Costs (Annual or Perennial) **Worksheet 5.** Future Research Plans **Instructions**

EPA Form # 4900-136 Pre Plant

**Printing worksheets** If you would like to print all worksheets that are contained in this workbook, go to the menu bar at the top of the screen and select "File" and then "Print." Then in the section of the menu that appears called "Print what," select "Entire W orkbook." To increase or decrease the size of the page that is viewable on the screen, go to the menu bar and select “View” and then “Zoom”. **Nav igating between worksheets**  **Copy ing and pasting an entire worksheet’s contents into a blank worksheet:**  **1.** Select the worksheet to be copied by clicking on the worksheet tab at the bottom of the screen. The tab will turn white in color when it has been selected. **2.** Select the top left corner of the worksheet (this is the space to the left of column A and above row 1. Y ou will know that the entire worksheet has been selected because the row and column marks as well as the worksheet itself will change to a

Note: This is the only

way you can copy a worksheet and not lose portions of the text instructions. **Viewing worksheets**

The set of four arrows on the bottom left of the screen will help you navigate between worksheets. This is necessary to access the remaining worksheet tabs in the workbook that are not viewable. The two arrows with vertical lines to either the left or right will take you to the first worksheet and to the last worksheet respectively in the workbook. The inner two arrows allow you move the worksheet tabs to the right or to the left incrementally

. The two arrows on the bottom right of the screen allow you to move the worksheet that you are viewing to the right or to the left. This is useful if the viewable area of on the screen is smaller than the entire page that is in the worksheet. OMB Control # 2060-0482, Expires 6/30/2015

**7.** Change the title row of the newly pasted worksheet from the old worksheet number to be consistent with the worksheet tab.

Wo rksheets are best viewed in "Page Break Preview." To select the view of the worksheet, go to the menu bar and select "View" and then "Page Break Preview." Page break preview shows only the printable area of the worksheet, with the blue lines that surround the screen indicating the edges of each page. **3.** Go to the menu line at the top of the worksheet and select “Edit” then “Copy ”. **4.** Go to the blank worksheet where you want the copied information to be pasted.**Yes No** 

**Cell Fax** 

**Cell Fax** 

EPA Form # 4900-136 Pre Plant Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Public reporting burden for this collection of information is estimated to average 38 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many individual users of methyl bromide. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current OMB control number. **Date** I certify that all information contained in this document is factual to the best of my knowledge.

**Signature Is this information Confidential Business Information?** 

Information in this application may be aggregated with information from other applications and used by the United States government to justify claims in the national nomination package that a particular use of methyl bromide be considered "critical" and authorized for an exemption beyond the 2005 phaseout. Use of aggregate data will be crucial to making compelling arguments in favor of critical use exemptions. **By signing below**  , you agree now to assert any claim of confidentiality that would affect the disclosure by EPA of aggregate information based in part on information contained in this application.

**Print Name Ad**  **dress**

**Date Title**  **Ag ronomic**  **Economic** 

# Worksheet 1. Contact & Methy **l Bromide Request Information for 2016** The following information will be used to determine the amount of methyl bromide requested and the contact person for this request. It is important that we know whom to contact in case we need additional information during the review of the application.

**Title**

**Signature** If yes, the applicant assumes responsibility for the secure transmission of electronic submissions. **Ap plicant Name**  **Primary Contact Contact Name**  (Check One) **Specialty Economic**  **Ag ronomic** 
**Day time Phone**  **E-mail Address Alternate Contact**  **Contact Name Specialty**  **Ad dress** 
**Day time Phone**  **E-mail Address**

**Print Name** OMB Control # 2060-0482, Expires 6/30/2015**1. Location** 

**2. Crop/Crop Grouping** 

**3. Summary** 

**of Crop Sy stem** 

**4.**

**5. Climate Zone**  Zones: (check all that apply) **6. Soil Ty**  **pe & Organic Matter**  **Light Medium**  **Heavy 0 to 2 %**  **2 to 5 % over 5 %**  **7. Yes**  **Pounds No**  **8. Yes**  **CUE # No**  **9.**

**A B** 
**C**

**D E**  **F**
**10.**

EPA Form # 4900-136 Pre Plant **Formulation (Ratio of MB/Pic Mixture) to be Used for the CUE** 
**Use Rate (lbs a.i./acre) Total A**  **rea to be Treated with the Methy l**  **Bromide or MB/Pic Formulation If strip, then what percentage is treated**  **with strip formulation? (E.g., If 30 inches out of a total of 60 inches are treated with**  **strip, the percent is 50%) Total Pounds A** **ctive Ingredient (a.i.) of Methy**  **l Bromide** (Insert number or percentage of users in each category) **200 - 400 acres 25 - 50 acres** 

(check all that apply)

**Year of Exemption Request 2015 (supplemental)**  **2016**

**Use: Broadcast or Strip/Bed Treatment What is the amount of methy**  **l bromide being requested by this application ? (Do NOT include QPS amounts)**  If a consortium is submitting this application, the data should be the total for the consortium. **Range of acres farmed by growers included in this application** 

**0 - 25 acres 50 - 100 acres**  **100 - 200 acres** (Enter the type of crop system used, e.g., open field [including tunnels added after treatment], permanent glasshouses [enclosed], open ended polyhouses, others [please describe])

**over 400 acres** (Enter the state, region, or county.)

(Indicate the soil type and percent organic matter where methyl bromide would be applied.) (Indicate the climate zone designation by reviewing the U.S. climate zone map located at the end of this workbook or online at http://planthardiness.ars.usda.gov/PHZMW eb.) **1____ 2a____ 2b____ 3a____ 3b____ 4a____ 4b____ 5a____ 5b____ 6a____ 6b____ 7a____ 7b____ 8a____ 8b____ 9a____ 9b____ 10a____ 10b____ 11____** 

**Organic Matter: Soil Ty**  **pe:** 

# Worksheet 1. Contact & Methy **l Bromide Request Information for 2016**

**Is this applicant eligible for Quarantine and Preshipment (QPS) uses of methy l**  **bromide? Has this applicant previously**  **applied for Critical Use Exemption of methy l bromide?**  OMB Control # 2060-0482, Expires 6/30/2015

**Please explain why**

**there may**

**be variations in the pounds or acres treated from y ear to y** **ear, especially if the request is higher this y**  **ear than in previous y** **ears:** (Include all crops/crop groupings that benefit from an application of methyl bromide in a fumigation cycle. For a definition of fumigation cycle see W orksheet entitled "Definitions".)**11.**

**12.**

**12a.**

**13. Yes**  **Lbs No**  **14. Have you adjusted the request for the following issues? Regulatory** 

**Issues: Yes___ No___ Disease Pressure: Yes___ No___**  **Soils Issues: Yes___ No___ Other (Please Explain): Yes___ No___**  

# Worksheet 1. Contact & Methy **l Bromide Request Information for 2016**

**For the region where methy l bromide is being requested, if only**  **part of the crop area is treated with methy l bromide, indicate the reason why**  **methy l bromide is not used in the other area. Additionally**  **, identify what alternative strategies are used to control the target pathogens and**  **weeds without methy l bromide in that area.**  **Please explain why**

**methy l bromide is being requested.** 

**Do y ou anticipate that y**  **ou will have any methy**  **l bromide in storage after January** 

**1, 2015?**

EPA Form # 4900-136 Pre Plant If yes, please specify amount (in pounds). **Would it be feasible to expand the use of these methods to cover at least part of the crop that has requested use of methy l bromide? What**  **changes would be necessary to enable this?** 

### Worksheet **Title**

**2-A Me**  **thyl Bromide - Crop & Pest Information**

If a consortium is submitting this application, the data for this table should reflect the **representative user** for the consortium. The purpose of this worksheet is to determine pest infestation and crop information where methy l bromide is used. This forms the baseline for evaluating the impacts of using an alternative to replace methy l bromide. **2-B Me**  **thyl Bromide - Historical Use 2008 - 2012**

If a consortium is submitting this application, all data should reflect the **actual data** for the consortium. This worksheet provides data in actual usage for 2008-2012. **2-C Me**  **thyl Bromide - Crop/Crop grouping Yield and Gross Revenue for 2008-2012**

If a consortium is submitting this application, the data for this table should reflect the **representative user** for the consortium. This worksheet provides crop/crop grouping y ield and gross revenue for 2008 through 2012. The purpose of this worksheet is to determine past gross revenues when methy l bromide is used. This forms the baseline for evaluating the revenue impacts of using an alternative to replace methy l bromide. **2-D(1 & 2) Me**  **thyl Bromide - Baseline - Operating Costs for 2012**

If a consortium is submitting this application, the data for this table should reflect the **representative user** for the consortium. This data is needed to estimate a baseline for operating costs in order to estimate **changes in costs** and the im pact on operating profit and short-run economic viability as a result of not using methy l bromide and to provide required information to the international review board. The purpose of this worksheet is to determine operating expenses when methy l bromide is used. This forms the baseline for evaluating the cost impacts of using an alternative to replace methy l bromide. The data requested are designed to help you identify how your operation would change if methy l bromide were unavailable, which will be shown in W orksheet 3-B. W orksheet 2-D(1) is for users with a fumigation cy cle of less than 5 years. W orksheet 2-D(2) is for users growing perennial crops following a single fumigation at establishment. **In collaboration with USDA , we will estimate fixed and overhead costs across crops and regions to**  **ensure consistency within the U.S. nomination.**

EPA Form # 4900-136 Pre Plant OMB Control # 2060-0482, Expires 6/30/2015


### Purpose of Data: To establish a baseline estimate of crop/crop grouping yields, gross revenues and costs using **methyl bromide.** Instructions specific to each worksheet are located at the top of each sheet.



# Worksheet 2. Methyl Bromide

### 1. **Crop/Crop Grouping or**

**Consortium**

**2. Jan**  **Feb Mar**  **Apr May**  **Jun Jul**  **Aug Sept**  **Oct Nov**  **Dec**

**3. Fumigation and Crop**  **Timeline**

**Beginning Fumigation Cycle Month**  **1 Month**  **2 Month**  **3 Month**  **4 Month**  **5 Month**  **6 Month**  **7 Month**  **8 Month**  **9 Month**  **10 Month**  **11 Month**  **12** 

### Land Preparation **Fumigation Planting**  **Harvest Fallow**  **Other Key Crop Steps Other Key Pest Steps**  **Continuation of Fumigation Cycle (if needed)**  **Month 13**  **Month 14**  **Month 15**  **Month 16**  **Month 17**  **Month 18**  **Month 19**  **Month 20**  **Month 21**  **Month 22**  **Month 23**  **Month 24**  

### Land Preparation **Fumigation Planting**  **Harvest Fallow**  **Other Key Crop Steps Other Key Pest Steps** 
**4. Which month does your fumigation cycle start?**  (check only one)

**Time Interval (e.g. MONTH/YEA R/SEA** **SON)**

**Comments: What is the typical soil temperature range during methyl bromide fumigation (e.g., 60-65°F)?**  **_____to_____°F** ( **Indicate w hen fumigation, major crop and pest management practices typically occur**  **by shading the appropriate cells.** Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/crop groupings not grown sequentially, they will need to provide this information for all crops/crop groupings. Please adjust timeline as necessary. **Please provide additional comments or description below or on a separate page.**  Please begin the timeline with the first land preparation. For **perennials** , please begin with the **year** of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) OMB Control # 2060-0482, Expires 6/30/2015

EPA Form # 4900-136 Pre Plant 

# Worksheet 2-A **. Methyl Bromide - Crop & Pest Information**

**Time Interval (e.g. MONTH/YEA R/SEA** **SON)**

### 5. **Target Pest(s) or Pest**

**Problem(s):**

**Pest 1 Pest 2**  **Pest 3 Pest 4**  **Pest 5**
**6. Pest Economic Threshold**  **Year**

**Pest 1 Pest 2**  **Pest 3 Pest 4**  **Pest 5**

**7. Target Pest Infestation** 

**Pest 1 %**  **Pest 2 %**  **Pest 3 %**  **Pest 4 %**  **Pest 5 %**  **8. Representative User :**  **Threshold** (Please provide the economic threshold information for each pest. Describe year and source of information such as survey or expert estimate.) **Source**

(Please provide descriptive factors regarding your operation.) 

### Ac **res** Average farm size Average acres in **this** crop Average area treated with methyl bromide: **Ac res**  Describe a few crops that could follow **this** crop: **Source**

**Ac res**  

# Worksheet 2-A **. Methyl Bromide - Crop & Pest Information**

**Specific Reasons w hy**  **Methy l Bromide is Needed**  OMB Control # 2060-0482, Expires 6/30/2015



### Units (e.g. **pests/sq ft) Common Name**  **Genus** (Please identify the key target pests or pest problems for which methyl bromide is reqested. Provide at least common name and genus and species if possible. Additional pests or pest problems can be provided as an attachment. Please also explain the specific reasons why methyl bromide is being requested for each pest [e.g., effective herbicide is available, but not registered for this crop; mandatory requirement to meet certification for disease tolerance])

**Percentage of Total Grow**  **ing Area**

EPA Form # 4900-136 Pre Plant 

### Other descriptive factors regarding representative user: (Please estimate the percentage of the consortia's total growing area with a moderate to severe problem with these pests. Describe source of information such as a survey or expert estimate.)**Row B:** 

**2008 2009**  **2010 2011**  **2012**

**A Total Pounds A**  **ctive Ingredient (a.i.) of Methy**  **l Bromide**  **B Use: Broadcast or Strip**  **Bed Treatment**

**C If strip, then w**  **hat percentage is treated w**  **ith strip formulation? (E.g., if**  **30 inches out of a total of 60 inches are treated w**  **ith strip, the percent is 50%)**  **D Formulation (Ratio of**  **MB/Pic Mixture) to be Used for the CUE**  **E Total A**  **rea to be Treated wi**  **th the Methy l Bromide or**  **MB/Pic Formulation F**  **Use Rate (lbs a.i/acre) Total A**  **rea to be Treated w ith the Methy**  **l Bromide or MB/Pic Formulation** Enter the total actual pounds active ingredient (a.i.) of methyl bromide applied. Note: This number should be the total pounds a.i. applied by the individual user or the entire consortium, for the year indicated. Include only the pounds active ingredient of methyl bromide. Do not include the pounds of chloropicrin that may be part of the same product.
**If strip, then w hat percentage is treated w**  **ith strip formulation? Use: Broadcast or Strip Bed Treatment**  **Row A**  **:**

**Row C:**  **Total Pounds A ctive Ingredient (a.i.) of Methy**  **l Bromide**

Indicate whether broadcast or strip bed Treatment is used. OMB Control # 2060-0482, Expires 6/30/2015

**Row D:** 

**For as many**

**y ears as possible as**  **show n specify**  **:**

If strip treatments are used, enter the percentage treated with strip formulation (e.g., if 30 inches out of a total of 60 inches are treated with strip, the percent is 50%).

**Use Rate (lbs a.i/acre)** Enter the use rate in pounds a.i. of methyl bromide per area. **Row E:**  

# Worksheet 2-B. Methyl Bromide - Historical Use for 2008-2012

Enter the formulation of methyl bromide used (e.g. MB 98:2; MB/Pic 70:30). **Formulation (Ratio of MB/Pic Mixture) to be Used for the CUE**

EPA Form # 4900-136 Pre Plant **Comments: If there is a variation (greater than 10%) in the quantity**  **a.i., the acres treated or average application rate from y ear**  **to y ear, please explain the reasons for the variation.**  **What is the frequency of methy**  **l bromide applied per area? (1x / y ear, 2x / y** **ear, 1x / 3 y ears, etc.)**  **_________ times per ____________** Enter the method by which methyl bromide is applied (e.g., injected at 3 inch depth, hot gas). **Row F:** 

### Column A **:**

**Column B:**

**Column C:**

**Column D:**
**Column E:**
**Column F:**
**Column G:**

**A B**  **C D**  **E F**  **G Year**  **Crops/Crop**

**Groupings Ma**  **rket Category Yield**  **Unit of Me**  **asurement Price ($)**  **Gross Revenue per**  **Ac re ($)**  **Year**

**Crops/Crop Groupings**

Enter average prices received by the users for that crop/crop grouping and market category. Average price over all categories can be calculated separately, if needed. Enter marketing categories that determine prices received, for example, grade (size, color), timeliness (early season, late season), or end use (fresh, processing). Itemize or aggregate these factors to the extent appropriate if lack of methyl bromide would affect the yields in each category. OMB Control # 2060-0482, Expires 6/30/2015



### Yield

**Gross Revenue Price**  Enter the unit of measurement for each crop/species (lbs, cwt, carton, bin). If not by weight, specify in the comments section the average weight of the measure. 

### Units of Measurement 

# Worksheet 2-C. Methyl Bromide - Crop/Species Yield & Gross

**Rev enue for 2008-2012** 

**Ma rket Categories**  Be sure to enter the year. Use as many rows as needed for each year for all the crops/crop groupings in the fumigation cycles from 2008 to 2012. If a fumigation cycle overlaps more than one calendar year, then the year of the fumigation cycle is the year methyl bromide was applied. Enter all crops/crop groupings that benefit from methyl bromide in the fumigation cycle. If multiple crops/crop groupings are grown during the interval between fumigations (e.g. tomatoes followed by peppers in a single growing season, or strawberries followed by lettuce over 2 or 3 years) include all of the crops/crop groupings during the entire interval.

Enter the yield per acre, or the proportion of total yields, obtained for that category. For perennial crops, please enter yields at full production. Be sure to indicate yields at other stages in the timeline in W orksheet 2-A. If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have the quantitative data for the crops/crop groupings grown on the same land, please indicate so in the comments section below.



### Comments:

EPA Form # 4900-136 Pre Plant 

### If this application is for multiple crops/crop groupings (e.g. nurseries producing evergreens, deciduous, and forbs) **please indicate the proportion of land area allocated to each crop/crop grouping.**

Gross revenue per acre for each market category and or each crop/crop grouping may be calculated using the data you entered as price times yield. If revenue is not equal to price times yield, you may enter a different revenue amount, but please explain the difference in the comments section below.

### Column A **:**

**Column B:**

**Column C:**

**Column D:**

**Column E:**

Harvest costs may likewise be calculated as costs per acre (Column B) plus variable costs per unit of y ield (Colum n C) times y ield (Colum n D). **Total Cost per A cre**  **Unit Costs**

**Total Cost per A cre**  **Quantity Used per A cre** 
**Constant Cost per A cre**  For harvest operations, specify costs that depend on land area, for example, picking costs, per acre of land.
**Cost per Unit of Yield** For harvest operations, specify costs that depend on amount of product harvested, for example, packing material, per unit of produce. **Operation / Input for Perennial Crops** For perennial crops (W orksheet D(2)), we have divided the lifespan into three basic periods: pre-production (including establishment), initial production, and full production. Please ensure that the timeline in W orksheet 2-A indicates the y ears of each period. Operating costs should be an average of costs incurred during each period. Please consider expected replanting rates and indicate which y ear dead or poorly performing young trees would be replaced. You m ay

copy columns/rows as needed if these periods need to be refined for y our situation.

EPA Form # 4900-136 Pre Plant



### For inputs and operations detailed in Columns B and D, total costs can be calculated as Column B times Column D. Otherwise, enter total cost of the input or operation. **As a check, you may add up Column E to obtain an**  **estimate of total variable operating costs. These will not include fixed and overhead costs, nor a return to the owners' labor. It should, therefore, be less than gross revenues calculated in Worksheet 2-C. If it is not,**  **please explain (for example, unusually poor yields or unusually poor prices).** For perennial crops, Column E should only

be totaled for the years at full production. For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of apply ing me thy l bromide, including any material costs, for example, tarps. If custom applied and separate costs are unavailable, write 'custom' and enter total cost in Column E. For all inputs and operations detailed in Column B, please specify the units of measurement.

**Yield** For harvest operations, indicate average y ields or representative y ields from W orksheet 2-C. **Units** OMB Control # 2060-0482, Expires 6/30/2015 

# Worksheet 2-D(1&2). Methyl Bromide - Baseline - Operating Costs **for 2012** Enter all operating costs incurred during a fumigation cy cle. Users with a relatively short fumigation cy cle (less than five years) should use version D(1); users cultivating perennial crops should use version D(2). Users with multiple crops, either on the same area in a single fumigation cy cle or on different areas treated separately , should copy this sheet and provide costs for each crop. If multiple crops are cultivated sequentially following a single fumigation, replace fumigation costs in pre-plant operations with any additional pest control costs used prior to the following crops. If a fallow season is an important part of the fumigation cy cle, include costs incurred (for example, cultivating a cover crop) as a separate line or as a separate sheet, if costs are extensive. **Please fill in the unshaded areas. The shaded areas can be used if the information is known.**

The operations/inputs listed here are not meant to be exhaustive or representative of your specific production system. They

are meant to provide suggestions and to help you identify how your operation would change if methy l bromide were unavailable. Be as precise as necessary otherwise you may

aggregate operations or inputs. For example, specify

herbicide costs if additional treatments would become necessary with the use of a methy l bromide alternative, otherwise you may simply specify total pesticide costs. **Please specify only variable operating costs.**

This field is required only for methy l bromide. However, you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant. **Operation / Input**

### B C D E **Quantity Used per Ac**  **re Units** 

**(lbs, hours, etc) Unit Cost ($)**  **Total Cost per Ac**  **re ($)**

**Constant Cost per Ac**  **re ($) Cost per Unit of** 

**Yield ($) Yield**  **Total Cost per Ac**  **re ($)**

Grading / Packing / Storage Other Costs Fungicide Nematicide Irrigation

**Harvest Operations** Labor Hauling Material Labor (manual) Fuel / Machine Labor Other Costs **Cultural Operations** Seed / Seedlings Fertilizer / Soil Am endm ents Pesticides Insecticide Herbicide application Irrigation Other costs **Pre-plant Operations** Land preparation Fumigation product (methy l bromide) **Operation / Input** OMB Control # 2060-0482, Expires 6/30/2015

EPA Form # 4900-136 Pre Plant



### A 

# Worksheet 2-D(1). Methyl Bromide - Baseline - Operating Costs **for 2012**

### A **B (1) C (1)**  **D (1) E (1)**  **B (2) C (2)**  **D (2) E (2)**  **B (3) C (3)**  **D (3) E (3)** 

**Operation or Input Quantity**  **used per acre**  **Units (lbs,**

**hours, etc) Unit Cost**  **Total Cost per Acre**  **Quantity**

**used per acre**  **Units (lbs,**

**hours, etc) Unit Cost**  **Total Cost per Acre**  **Quantity**

**used per acre**  **Units (lbs,**

**hours, etc) Unit Cost**  **Total Cost per Acre**  

### Establishment Operations Land preparation Fumigation product application Irrigation Seedlings Other costs **Cultural Operations** Fertilizer/soil am endm ents Pesticides Insecticide Herbicide Fungicide Nematicide Irrigation Labor (manual) Fuel/machine labor Other costs
**Harvest Operations Constant**  **Cost per Acre**  **Cost per**

**Unit of Yield**  **Yield Total Cost**  **Constant Cost per**  **Acre Cost per** 

**Unit of Yield**  **Yield Total Cost**  **Constant Cost per**  **Acre Cost per** 

**Unit of Yield**  **Yield Total Cost**  

### Picking/hauling Material Grading/packing Other costs OMB Control # 2060-0482, Expires 6/30/2015

EPA Form # 4900-136 Pre Plant 

# Worksheet 2-D(2). Methyl Bromide - Baseline - Operating Costs for Perennial Crops

**INITIA L PRODUCTION YEA**  **RS _____ FULL PRODUCTION YEA**  **RS _____ PRE PRODUCTION YEA**  **RS _______ Worksheet** 

**3-A**

**3-B**

**3-C**

EPA Form # 4900-136 Pre Plant

**Al ternativ**  **es - Changes in Operating Costs** 

# Worksheet 3. A **lternativ es - Feasibility**  **of A lternativ**  **e Pest Control Regimens** 

**Title** You must complete one worksheet for each alternative. Please inset the name of the alternative in the area on top of the page. If you prefer, y ou may provide the information requested in this worksheet in a narrative review. However, y ou must fill in the information in Question #1 and #3 or we will assume no y ield or quality loss. **Al ternativ**  **es - Technical Feasibility of A**  **lternativ es to Methy**  **l Bromide** 

### Purpose of Data: To estimate the loss as a result of not having methyl bromide available. EPA needs to compare data (yields, crop/species prices, gross revenues and costs) on the use of methyl bromide and alternative pest control regimens. Complete worksheet 3-A for each alternative pest control regimen. Each worksheet contains a place holder in the title for you to insert the name of the specific alternative pest control regimen addressed. You should add additional worksheets as required. Enter all alternative pesticides and pest control methods (and associated cost and yield data) that would replace one treatment of methyl bromide throughout the fumigation cycle. See the Definition worksheet for a comprehensive definition on fumigation cycles. OMB Control # 2060-0482, Expires 6/30/2015

If a consortium is submitting this application, the data for this table should reflect the **representativ e user**  for the consortium. This data is needed to estimate **changes in costs** and the impact on operating profit and short-run economic viability as a result of not using methy l bromide and to provide required information to the international review board.

The purpose of this worksheet is to determine operating expenses when alternatives are used for evaluating the cost impacts of using an alternative to replace methy l bromide. The data requested are designed to help you identify how your operation would change if methyl bromide were unavailable. W orksheet 3-B(1) is for users with a fumigation cy cle of less than 5 y ears. W orksheet 3-B(2) is for users growing perennial crops following a single fumigation at establishment.

**Please include in this w orksheet data for each alternativ**  **e included in w orksheets 3-A**  **and 3-B. In collaboration w**  **ith USDA , we will estimate fixed and ov**  **erhead costs across crops and regions to ensure consistency** 

**within the U.S. nomination. Please fill out this w**  **orksheet for each alternativ e for w**  **hich the economic ev aluation w**  **ould bolster the case that methy**  **l bromide is needed.**

**Al ternativ**  **es - Economic Feasibility of A**  **lternativ es to Methy**  **l Bromide** If a consortium is submitting this application, the data for this table should reflect the **representativ e user**  for the consortium.**Study #**

**1 2**  **3 4**  **5**

**Units Units** 

**No Quality Impact Description**  **Market Category Quality Loss ** * **Yield With Alternative**  Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease vector, etc. **Refer to market category question in Worksheet 2-C. Yield with**  **Methyl Bromide**  **Enter Average Loss**
**Study Information Details** 

**5 4**  **3 2**  **Details 1**  **Study # (list below) Pest Being Tested** 

- Label Restriction Regulatory Restriction

Organic Matter Restriction Off Site Damage (outgassing) Other Restrictions (Describe) - Tow nship Caps Pest Resistant To Alternative **Details** 

## Al **ternative: [ Insert Alternative ]**  **Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide** Provide numerical estimates where possible. Add additional rows if necessary.

**Attached?** * If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available. For the information in #1 above list: the study name, authors, publication, date, and if a copy is attached. **% Yield Loss *** **% Pest Control ***

Soil Restriction This information will be used to determine the amount of methyl bromide needed. **Restrictions on Alternative Use Are there any variety or cultivar issues associated with this alternative?** 

EPA Form # 4900-136 Pre Plant **% of Area** OMB Control # 2060-0482, Expires 6/30/2015 

# Worksheet 3-A **. A lternativ**  **es - Technical Feasibility of A**  **lternativ es to**  **Methy l Bromide** 

**Are there any production delays (planting/ harvesting) associated with this alternative?** (If yes, please explain) **Yes Month**  **1 Mont**  **h 2 Month** 

**3 Month** 

**4 Month** 

**5 Month** 

**6 Month** 

**7 Month** 

**8 Month** 

**9 Month** 

**10 Month** 

**11 Month** 

**12**

**Month 1**  **Mont h 2**  **Month**

**3 Month** 

**4 Month** 

**5 Month** 

**6 Month** 

**7 Month** 

**8 Month** 

**9 Month** 

**10 Month** 

**11 Month** 

**12 Units**  (gals, lbs. Etc.)

Fumigation **Use Rate of Chemical Alternative: Quantity a.i. per**  **Acre # of Acres**  **Treated # of Applications** 

**per Year Active Ingredient (a.i.)**  **Name of Product and Formulation**

( **Indicate when fumigation, major crop and pest management practices typically occur by shading the appropriate cells.**  Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one year change the months to an appropriate interval. These tables are for annual crops but more than one crop may benefit from one methyl bromide fumigation. If application covers multiple crops/crop groupings not grow n sequentially, they w ill need to provide this information for all crops/crop groupings. Please adjust timeline as necessary. **Please provide additional comments or description below or on a separate page.** Please begin the timeline w ith the first land preparation. For **perennials** , please begin w ith the **year** of land preparation and fumigation and indicate the years of production by yield or percentage of full production.) **Alternative Timeline: Non-Chemical Pest Control:**  (please describe)

Fallow 

## Al **ternative: [ Insert Alternative ]** 

Planting Harvest Fallow Other Key Crop Steps Other Key Pest Steps Land Preparation

Harvest **Continuation of Alternative Cycle (if needed)**  **Time Interval (e.g. MONTH/YEAR/SEASON) Beginning Fumigation Cycle** 

Planting **Time Interval (e.g. MONTH/YEAR/SEASON)** Fumigation

Land Preparation

Other Key Crop Steps

EPA Form # 4900-136 Pre Plant **Comments:** Other Key Pest Steps 

# Worksheet 3-A **. A lternativ**  **es - Technical Feasibility of A**  **lternativ es to**  **Methy l Bromide**  OMB Control # 2060-0482, Expires 6/30/2015

### Column A **:**

**Column B:**

**Column C:**

**Column D:**

**Column E:** For inputs and operations detailed in Columns B and D, total costs can be calculated as Column B times Column

D. Otherwise, enter total cost of the input or operation. As a check, you may add up Column E to obtain an estimate of total variable operating costs. These will not include fixed and overhead costs, nor a return to the owners' labor. It should, therefore, be less than gross revenues calculated in W orksheet 2-C. If it is not, please explain any

variations in y ields and prices. For perennial crops, Column E should only be totaled for the years at full production. For all inputs and operations detailed in Column B, please specify the units of measurement.

**Yield** For harvest operations, indicate average y ields or representative y ields from W orksheet 3-A. **Total Cost per A cre** 

**Total Cost per A cre**  Harvest costs may

likewise be calculated as costs per acre (Column B) plus variable costs per unit of y ield (Column C) times y ield (Colum n D). EPA Form # 4900-136 Pre Plant



### For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of apply ing me thy l bromide, including any material costs, for example, tarps. If custom applied and separate costs are unavailable, write 'custom' and enter total cost in Column E. **Cost per Unit of Yield** For harvest operations, specify costs that depend on amount of product harvested, for example, packing material, per unit of produce. **Unit Costs Operation / Input for Perennial Crops**  For perennial crops (W orksheet B(2)), we have divided the lifespan into three basic periods: pre-production (including establishment), initial production, and full production. Please ensure that the timeline in W orksheet 3-A indicates the y ears of each period. Operating costs should be an average of costs incurred during each period. Please consider expected replanting rates and indicate which y ear dead or poorly performing young trees would be replaced. You m ay

copy columns/rows as needed if these periods need to be refined for y our situation. **Quantity Used per A cre**  This field is required only for methy l bromide. However, you may include specific amounts of other inputs or operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant. **Constant Cost per A cre**  For harvest operations, specify costs that depend on land area, for example, picking costs, per acre of land. **Units** OMB Control # 2060-0482, Expires 6/30/2015 

# Worksheet 3-B(1&2). A **lternativ es - Changes in Operating Costs** 

Enter all operating costs incurred during a fumigation cy cle. Users with a relatively short fumigation cy cle (less than five years) should use version B(1); users cultivating perennial crops should use version B(2). Users with multiple crops, either on the same area in a single fumigation cy cle or on different areas treated separately , should copy this sheet and provide costs for each crop. If multiple crops are cultivated sequentially following a single fumigation, replace fumigation costs in pre-plant operations with any

additional pest control costs used prior to the following crops. If a fallow season is an important part of the fumigation cy cle, include costs incurred (for example, cultivating a cover crop) as a separate line or as a separate sheet, if costs are extensive. **Please fill in the unshaded areas. The shaded areas can be used if the information is known.**

**Operation / Input** The operations/inputs listed here are not meant to be exhaustive or representative of your specific production system. They

are meant to provide suggestions and to help you identify how your operation would change if me thy l bromide were unavailable. Be as precise as necessary otherwise you may

aggregate operations or inputs. For example, specify

herbicide costs if additional treatments would become necessary with the use of a methy l bromide alternative, otherwise you may simply specify total pesticide costs. **Please specify only variable operating costs.**  

# Al **ternative: [Insert Alternative]** 

### B **C D**  **E Quantity Used per**  **Ac re**  **Units**

**(lbs, hours, etc) Unit Cost ($)**  **Total Cost per Ac**  **re ($)**

**Constant Cost per Ac**  **re ($) Cost per Unit of** 

**Yield ($) Yield**  **Total Cost per Ac**  **re ($)** Hauling Material Grading / Packing / Storage Other Costs **Harvest Operations** Labor Fuel / Machine Labor Other Costs Fungicide Nematicide Irrigation Labor (manual) Fertilizer / Soil Am endm ents Pesticides Insecticide Herbicide **Cultural Operations** Seed / Seedlings Irrigation Other costs Land preparation Fumigation product (methy l bromide) application **Pre-plant Operations** 

# Al **ternative: [Insert Alternative]** 
**Operation / Input** 

# Worksheet 3-B(1). A **lternativ es - Changes in Operating Costs** 

**A** OMB Control # 2060-0482, Expires 6/30/2015

EPA Form # 4900-136 Pre Plant

# Al **ternative:**

**A B (1)**  **C (1) D (1)**  **E (1) B (2)**  **C (2) D (2)**  **E (2) B (3)**  **C (3) D (3)**  **E (3)**
**Operation or Input Quantity**  **used per acre**  **Units (lbs,**

**hours, etc) Unit Cost**  **Total Cost per A**  **cre Quantity**  **used per acre**  **Units (lbs,**

**hours, etc) Unit Cost**  **Total Cost per A**  **cre Quantity**  **used per acre**  **Units (lbs,**

**hours, etc) Unit Cost**  **Total Cost per A**  **cre** 

### Establishment Operations Land preparation Fumigation product application Irrigation Seedlings Other costs **Cultural Operations** Fertilizer/soil amendments Pesticides Insecticide Herbicide Fungicide Nematicide Irrigation Labor (manual) Fuel/machine labor Other costs
**Harvest Operations Constant**  **Cost per Ac**  **re Cost per** 

**Unit of Yield**  **Yield Total Cost**  **Constant Cost per**  **Ac re**  **Cost per**

**Unit of Yield**  **Yield Total Cost**  **Constant Cost per**  **Ac re**  **Cost per**

**Unit of Yield**  **Yield Total Cost**  

### Picking/hauling Material Grading/packing Other costs
EPA Form # 4900-136 Pre Plant OMB Control # 2060-0482, Expires 6/30/2015 

# Worksheet 3-B(2). A **lternatives - Changes in Operating Costs for Perennial Crops**

**PRE PRODUCTION YEA RS _______**  **INITIA L PRODUCTION YEA**  **RS _____ FULL PRODUCTION YEA**  **RS _____** 

# [ Insert A **lternative ] 1.** 

**2008** _____ lbs/acre **2013** _____ lbs/acre **2012** _____ lbs/acre **2017** _____ lbs/acre **2008** ____ times per____ **2013** ____ times per____ **2012** ____ times per____ **2017** ____ times per____ **2008** _____% methyl bromide, _____% chloropicrin **2013** _____% methyl bromide, _____% chloropicrin **2012** _____% methyl bromide, _____% chloropicrin **2017** _____% methyl bromide, _____% chloropicrin **2008 2013**  **2012 2017**  **2008 2013**  **2012 2017**  **2008 2013**  **2012 2017**  **2008 2013**  **2012 2017**  **2008 2013**  **2012 2017**  **2008 2013**  **2012 2017**  **2008 2013**  **2012 2017** 
**2.** 

# Worksheet 4. Emission Control OMB Control # 2060-0482, Expires 6/30/2015
**How do y ou currently**  **minimize use and/or emissions of methy l bromide, and how do y** **ou plan to further reduce use and/or emissions in the future?**  (For all use/emissions reduction technique that you use, please fill out the text, where provided, or state the adoption rate and/or describe changes.) **What use/emission reduction methods are presently** 

**adopted? Please state the emission reduction amounts between each listed y**  **ear. What further use/emission reduction steps**  **will be taken for the methy l bromide used for**  **critical uses? Please project the reduction amounts for each y** 

**ear.**
**Less Frequent A pplication** 

**Cultural Practices (please specify** **)**

EPA Form # 4900-136 Pre-Plant **Methy l Bromide Rate**  **Reduction**

**Formulation Changes (please specify** 

**)**

**If methy l bromide emission reduction techniques are not being used, or are not planned for the future, state reasons:**  **Tarpaulin (High Density Poly**  **ethy lene)**  **High Barrier Films Virtually**  **Impermeable Film (VIF)** 

**Other Pesticides (please specify** **) Non-Chemical Methods**  **(please specify**

**) Other Measures (please**  **specify )** **1. 1**  **4**

**2 5**  **3 2.**  **1 4** 

**2 5**  **3 3.**  **1 4** 

**2 5**  **3 4.** 

**5.**

**6.**

**7.**

**8.**

**9. Yes**  **No 10.**  **Yes No** 
**11. Years**  **Amount ($)**

**12.** $ **Cost**

**13. What is the cumulative amount spent and the ty**  **pes of contributions this consortium has made to fund research to develop alternatives to methy**  **l bromide since 1992?** (e.g. consortium dues, direct research funding, etc.) **Name of Organization / Research Institution Are there technologies being used to produce the crop which avoid the need for methy**  **l bromide? Please explain whether such technologies could replace a proportion of proposed methy**  **l bromide use. Yes___ No___ If yes, please describe:**

**Will y ield/quality** 

**loss be measured? Will economic impacts be measured?**  **Prioritize the alternative chemicals or cultural practices to be tested.**

**Are there any other potential alternatives under development which are being considered to replace methyl bromide? Yes___ No___ If y**  **es, please describe: What would be the best currently**  **available alternative if methyl bromide were not available?** 

# Worksheet 5. Future Research Plans Please describe future plans to test alternatives to methyl bromide. You may use this w orksheet to describe all future plans. **Identify the top 3 to 5 target pests for y**  **our research.**

**Provide a list of alternative chemicals or cultural practices that have been tested.**

EPA Form # 4900-136 Pre Plant **Grant requests made to USDA , EPA, state, or other funding group.**  **Investment Other total investments, if any, made to reduce your reliance on methyl bromide?**  OMB Control # 2060-0482, Expires 6/30/2015

(Describe each investment and its associated costs. e.g. specialized machinery, etc.) **Please provide an overview/timeline of the plan to transition away from using methyl bromide.**

**Please describe the management strategies that are in place or proposed to eliminate the use of methyl bromide for the nominated critical use, e.g., measures to avoid any increase in methyl bromide consumption, measure to encourage the use of alternatives,**  **information on the market penetration of newly deploy**  **ed alternatives and alternatives that may be used in the near future.**

### 1. **2. 3.**  **4. 2015**  **lbs. 2016**  **lbs. 5.**  **2015 Ac**  **res 2016**  **Ac res** 

**Not Technically**  **Feasible Not** 

**Economically Feasible**  **Consortium Name: Location:**  **For EPA Use Only** 

**ID # _______________ SECTOR __________________________**  

# Worksheet 6. A **pplication Summary** This worksheet will be posted on the web to notify the public of requests for critical use exemptions bey ond the 2005 phaseout for methy l bromide. Therefore, this worksheet cannot be claimed as CBI.

**Crop: Pounds of Methyl**  **Bromide Requested Ac**  **res Treated with Me**  **thyl Bromide** Place an "X" in the column(s) labeled "Not Technically Feasible" and/or "Not Economically Feasible" where appropriate. Use the "Reasons" column to describe why the potential alternative is not feasible. Please add additional rows if necessary

. **Potential A lternatives**  **Reasons** OMB Control # 2060-0482, Expires 6/30/2015

EPA Form # 4900-136 Pre Plant

### Fumigation cycle: The period of time between methy l bromide fumigations. **Year:** If a fumigation cy cle overlaps more than one calendar y ear, "y ear" refers to the calendar y ear when me thy l bromide is applied (or the beginning of the cy cle).
**Comparable data:** In order to compare revenues and costs with and without methy l bromide, data on alternatives for pest control, y ields, revenues, and costs must be for the same time interval as the methy l bromide fumigation cy cle. If, however, quantitative data, is not available for the entire fumigation cy cle, then to be comparable, the quantitative data for the alternatives should cover the same portion of the fumigation cy cle as the quantitative data for methy l bromide, and the rest of the cy cle should be discussed in the comments sections.

**2-year example:** If a methy l bromide fumigation is made every 2 y ears, then the 2003 fumigation cy cle began in 2003 and would end in 2005. The data should cover the methy l bromide costs and usage for the methy l bromide fumigation made in 2003, and all y ields and revenues received and other costs incurred during the 2 y ear period. To be comparable, the data on alternatives should cover a similar 2 year period beginning at the same time of y ear when a m ethy l bromide fumigation would be made. The data should cover all methy l bromide alternatives used, and all y ields and revenues received during that 2-y ear interval. Other pest control and other costs would only need to be provided for that interval if they

would change from what they were with m ethy l bromide. **Other beneficiary example**  If someone other than the applicant benefits from a methy l bromide fumigation, you should comment on these benefits if you do not have quantitative data for the entire fumigation cycle. For example, if a rotational crop in the second y ear benefits from a methy l bromide fumigation a y ear earlier, but there is quantitative data only on the first crop, then the data on the alternatives should cover only

the first crop, and the benefits of methy l bromide and the additional pesticides that would have to be used on the rotational crop should be discussed in the comments sections. **Crop cycle change example:**  If in a one year interval, methy l bromide is applied, tomatoes are grown and harvested followed by peppers, then the fumigation cy cle would be one y ear including the tomatoes and peppers. If, however, without m ethy l bromide, it is not possible to follow tomatoes with peppers in the same one ye ar interval, then the alternative data on pesticides, costs, y ields, and revenues should just cover tomatoes. The loss of profit from not being able to grow peppers with the alternatives would be part of the loss from not having methy l bromide.

**Crop Grouping** The applicant can group simliar crops together if: (i) Crops would experience similar y ield and quality losses in the absence of methy l bromide; and (ii) Crops are grown on the same fumigation and cultivation cy cle with sim ilar operating costs. For example, nursery

crops including various flower or tree species can be aggregated, with average y ields per acre and prices. However, if crops are distinctly different in revenues and operating costs, or the cy cles, the applicant may want to present y ield, price and operating costs for each crop separately

and also indicate the proportion of land area allocated to each crop. 

# Definitions OMB Control # 2060-0482, Expires 6/30/2015

EPA Form # 4900-136 Pre Plant